The DOL's Advisory Opinion 2025-04A clarifies that managed account solutions incorporating lifetime income products can qualify as Qualified Default Investment Alternatives under ERISA, provided they meet transferability and other regulatory requirements. Specifically, such solutions remain eligible even when offered through a variable annuity contract with a guaranteed lifetime withdrawal benefit.
Employers across the United States experienced significant legislative, regulatory, and judicial changes in the benefits landscape throughout 2025, developments that will shape plan sponsor and fiduciary strategies in 2026. This year brought notable advancements in employee benefits, and this article highlights the key trends from 2025 while offering a forward-looking perspective for the year ahead.
The matching formula in a retirement plan document, often seen as simple and predictable, can actually be a major source of compliance problems. While employers may assume it's straightforward and "set it and forget it," in reality, it frequently causes operational failures and costly corrective actions, making it one of the most common pitfalls for plan sponsors.
The Institutional Retirement Income Council forecasts that next year will see a significant shift toward broader adoption of in-plan retirement income solutions, driven by growing interest in retirement income innovation. In 2025, the industry focused on laying the groundwork through options like target-date funds, annuity marketplaces, systematic withdrawal programs, managed accounts with income features, and middleware integrations. By 2026, consultants and advisers are expected to implement standardized fiduciary evaluation frameworks to help plan sponsors assess, compare, and adopt these features.
Several major interest groups -- including the ERISA Industry Committee, U.S. Chamber of Commerce, and National Retail Federation -- filed a joint amicus brief with the U.S. 8th Circuit Court of Appeals. They urged the court to uphold a lower court's June ruling that dismissed a 401k forfeiture complaint against Wells Fargo. The original decision, issued by U.S. District Judge John Tunheim, found that the plaintiff, Thomas Matula Jr., a former employee and plan participant, failed to state a valid claim. Matula appealed dismissal in July.
Annually, the IRS releases updated indexed limits and cost-of-living adjustments for the upcoming tax year, affecting various provisions of the Internal Revenue Code, including income tax deduction rates and retirement plan contribution limits. This article explains how the updated maximum dollar limits apply across multiple defined contribution retirement plans.
Recent lawsuits have challenged 401k plan sponsors over using plan forfeitures to offset future employer contributions, even when allowed by plan documents. A California district court ruled in favor of the sponsor, stating such claims would add benefits not provided under the plan and conflict with ERISA's established practice of permitting forfeitures under plan terms. Similar rulings in Mississippi and Texas also supported employers.
A House Education and Workforce Subcommittee held a hearing titled "Pension Predators: Stopping Class Action Abuse Against Workers’ Retirement." Chairman Rick Allen emphasized the need to protect workers' retirement savings and employers from what he called baseless, predatory class action lawsuits. He highlighted that ERISA safeguards benefits for over 155 million Americans, with plans collectively holding more than $14 trillion to ensure financial security.
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Collected Wisdom™
Our researchers look for what they think are some of the better resources available to assist you in administering your plan or helping your clients. We group these resources in our COLLECTED WISDOM™ topics to make it easy for you to locate the information you need. Each item in a category contains a summary and date of when it was placed in the group.
We also maintain some older material in these collections for perspective and context.
